Business Risk Auditing and the Auditing Profession

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    Business Risk Auditing and the Auditing Profession:Status, Identity and Fragmentation

    Christopher Humphrey(Manchester School of Accounting and Finance,

    University of Manchester, Crawford House, Oxford Road, Manchester,M13 9PL, Tel. 44-161-275-4957, Fax. 44-161-275-4023:

    [email protected])

    Julian Jones(University of Manchester: [email protected])

    Rihab Khalifa(London School of Economics and Political Science:

    [email protected])

    &

    Keith Robson(UMIST: [email protected])

    The financial support of the Federal School of Business and Management,University of Manchester/UMIST facilitated the preparation of this paperand is gratefully acknowledged.

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    Business Risk Auditing and the Auditing Profession:

    Status, Identity and Fragmentation

    Abstract

    Pre-Enron, there was much anticipation that developments in risk-based audit methodologies

    were in the process of better systemising the knowledge base of auditing and enhancing its

    operational effectiveness. Post-Enron, those claims have been contested, with the accounting

    profession having to defend itself from allegations made by business and regulators that audit

    practice is flawed. This paper examines Business Risk Audit (henceforth BRA) as an

    institutional event (Burchell et al., 1985) through which to analyse and comment upon the audit

    industry and the accountancy profession in the UK. We examine BRA technique as a socialand institutional practice that auditors have to establish and negotiate with their environment

    (Hopwood & Miller, 1994). In order to embed BRA technique, audit firms have to establish

    legitimacy and enrol allies in the institutional environment (Latour, 1987). This in turn involves

    defining or redefining a claim or claims to knowledge upon which the profession stakes its

    professional status and jurisdiction (Abbott, 1988). The papers title signals three interrelated

    dimensions of this technical-professional interface: status, identity and fragmentation. The paper

    seeks to explore some of these key issues through documentary analysis and material derived

    from a series of interviews held with audit partners from a number of large, mid-tier and small

    audit firms with offices in Manchester and/or London, England and a limited number of former-

    audit staff now working in business consulting and private equity.

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    Introduction

    In 1999 KPMGs US Assurance and Advisory Services Center published the booklet The

    Financial Statement Auditwith the subtitle Why a New Age requires an Evolving Methodology.

    The publication profiles and publicizes the evolving audit methodology, with audit mutating to a

    risk based, strategic systems, methodology fit for the economy of the 21st

    Century (1999: p.4). While the text is a minor archetype of rhetorical justification, illustrating the critical force of

    language (Arrington, 1999), it also brings to the fore the problems that professional firms and

    institutions confront and the linguistic strategies they enact in order to justify and promote a new

    and abstract system of knowledge for a practice that few non-professionals, or lay-persons, can

    assess). The new audit methodology has been heralded as the audit of tomorrow (for

    example, see Stewart, 1998; 1999a; 1999b), and a complete transformation in assurance

    practices is said to be accompanying changes in the management and organization of todays

    corporations (for a review, see Lemon et al., 2000. The KPMG (and others, cf. Bell et al., 1997)

    document deploys many of the key tropes and symbols of modern management discourse to

    analyse a situation and outline the favoured answers. The language of transformation is very

    prominent. Much of the writing plays upon terms that both unsettle the reader and yet re-assure

    him or her that while serious challenges to business survival exist, solutions are at hand. The

    opening page cites the chair of the AICPA, O. Kirtley:

    People want to know more about what is going to happen tomorrow. The rules ofbusiness and the economy are changing. (KPMG, 1999:1)

    Adjacent to the above is another quotation from Frank O. Marrs, the Partner-in-charge of

    Assurance Services at KPMG suggesting that:

    Now the audit can do much more than confirm the financial statements; it can be animportant tool for helping management assess where their companies are, where theywant to be, and why they are not yet there (KPMG, 1999:1)

    The keyword is change; masses of processes are developing, evolving, usually at a more

    rapid pace or with greater frequency. With change, as the 20th Century draws to a close has

    come increased competition, heightened and more frequent demands, new and increasingly

    complex organizations which in turn fuel the need for new responses in the information age.

    Metaphors of change, speed and frequency are transformed into a subliminal question for the

    reader: are youbeing left behind? The document identifies the most important element or

    consequence of this global change as being risk:

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    Change translates into varied and ever-evolving risks - some that organizations mayrecognize or know how to identify and manage and others that are completely new tothem (KPMG, 1999: 2).

    Of course, to define financial reporting risk is to identify a constant of the audit process, but to

    understand new or developing risks requires a new audit methodology. Accordingly, KPMG has

    developed a new audit that is evolving to meet the changes. Setting this scene of rapid change

    and heightened risks for the evolving business environment, the pamphlet outlines the contrast

    between the traditional audit, suited to a prior age, and the new methodology in which analysis

    of business risk informs the assessment of audit risk, and hence the audit process and

    conclusions. Traditional audit is oriented towards compliance1, the evolving audit creates value,

    the traditional approach is transactions based, the evolving audit is risk based(KPMG, 1999:9).

    The text is mindful also to affirm the maintenance of core attributes such that, while audit

    methodologies appear to have new orientations, at the same time the auditors goal remains

    constant: to provide an independent opinion on whether an organizations financial statements

    are fairly stated in accordance with Generally Accepted Accounting Principles (KPMG, 1999:4).

    Audit may be evolving, but old values persist. Similarly, while the new risk based approach is

    central to this evolving audit, risk analysis in audit has also existed as a rudimentary approach

    since the first half of the 20 th Century.2

    In 2003, at the start of the twenty-first century, a readers reception of a text promoting Business

    Risk Based Audit Methodologies is, however, likely also to be evolving. Pre-Enron, there was

    much anticipation, fuelled by the Big 5 firms, that developments in risk-based audit

    methodologies were in the process of better systemising the knowledge base of auditing and

    enhancing its operational effectiveness. Post-Enron, those claims have been contested, with

    the accounting profession, rather than setting new agendas, having to defend itself from

    numerous allegations made by business, media, academics and regulators that audit practice or

    regulation (or both) is flawed.

    The UK accountancy bodies have attempted to define the Enron and WorldCom failures as

    peculiar to the US environment and the so-called cook-book approach of US GAAP. Yet the

    swift response of US Congress in passing the Democrat inspired Sarbanes-Oxley Act in July

    2002 and the desire to appoint an SEC Chairman deemed tough enough to address corporate

    governance and accountancys problems have not left the UK profession, and its principles-

    based approaches to regulation, immune from debates proposing the banning of consulting

    services, the need for compulsory auditor rotation, more detailed audit reporting and other

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    amendments to audit firm practices that address conceptions of the flawed independence of

    audit. Alongside more wide-ranging examinations of corporate governance and the role of non-

    executive directors (Higgs, 2003), the entire audit industry remains under the scrutiny of

    government, corporate directors, investors and the press (DTI, 2003). To date, the impact of

    Enron in the UK on audit activity has largely been reported in terms of increased insurance

    premiums and possible future opportunities to increase audit fees through the need for auditors

    to increase the level of audit work.

    Auditing Practice as an Agent of Institutional Change in the Accounting Profession

    It is now widely accepted that there is much to be gained from attempting to understand

    accounting in its social context (see, for example, Burchell et al., 1980, 1985; Cooper & Sherer,

    1984). Yet auditing research has remained relatively immune from the influence of this type of

    theorizing, particularly in terms of empirical analysis of contemporary audit practice. Much of

    the post-Enron analysis has focused on scandalous and emotive elements of the case, the

    technical complexities of accounting rules and practices, the excesses and abuses of corporate

    America, assessing whether such scandal(s) could happen in the UK or elsewhere, and

    proposing (and implementing) a range of reforms to improve corporate governance. The

    day-to-day professional and working environment of corporate external auditors and the impact

    that the Enron case has had upon them and their methods/practices has not attracted that much

    attention.

    At this juncture intriguing possibilities arise for the study of professional change in auditing

    practices and accountancy as an institution (Ackroyd, 1996). While certain writers have

    suggested that late modernity holds stimulating challenges to the role of professions (Reed,

    1996) and some others have developed a tradition in alternative critical studies of developments

    in audit methods (e.g. see Fischer, 1996; Humphrey and Moizer, 1990; Pentland, 1993; Power,

    1992; 1995) articles to date on the development of business-risk methodologies have tended to

    be assertive documents promoting change (e.g. Stewart, 1998, 1999a; 1999b) or have

    concentrated on the content of official, audit manuals of the large, multinational accounting firms

    (e.g. see Perrin, 1998; Lemon et al., 2000; Winograd et al., 2000). There have been no studies

    yet seeking to explore the way in which the implementation and application of new audittechnologies is shaped by the formal and informal processes and norms that make up the

    organizational culture of an audit firm (see Anderson-Gough, Grey & Robson, 1998; 2000 for an

    assessment of such factors in the making of the professional accountant).

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    This paper examines Business Risk Audit (henceforth BRA) as an institutional event (Burchell

    et al., 1985) through which to analyse and comment upon the audit industry and the

    accountancy profession in the UK. Our concern is not to offer a technical critique but to look at

    the technique of BRA as a social and institutional practice that auditors have to negotiate with

    their environment (Hopwood & Miller, 1994). In order to embed BRA, audit firms have to

    establish legitimacy and enrol allies in the institutional environment (Latour, 1987). This in turn

    involves defining or redefining a claim or claims to knowledge upon which the profession stakes

    its professional status and jurisdiction (Abbott, 1988).

    To this end our paper is concerned with the following connected issues: What is at stake in the

    development of a new audit methodology? How are new claims to knowledge articulated? To

    what constituencies are knowledge claims addressed? What were the conditions of possibility

    for BRAs emergence - to what conditions was BRA a response? In what network of

    relationships was BRA established and then embedded (insofar as this has already been

    achieved), and what effects have this (mere) audit methodology had upon the institutional

    configuration of the profession and the organizations in which it is practiced? Are there

    challenges that still or have since arisen to face the ascendance of Business Risk Auditing? We

    suggest that the BRA event is not simply indicative but productively revealing of the changing

    character of the accountancy profession in the UK, the status of auditing and the professional

    identity of auditors - in the Big Firms, of course, but also in contrast to the professional self-

    image of accountants and the norms and beliefs of auditors in small and medium sized firms.

    The research is based in part upon historical research and analysis of the professional and

    academic literature concerned with describing and tracing BRA. Professional and firm

    documents concerned with auditing regulation, audit practice and proposed changes to

    professional practices, such as education and training, have been reviewed. Interviews were

    also held with audit partners and senior managers from a range of Big 4, mid-tier and small

    accountancy firms with offices in Manchester and London, England and with a limited number of

    former auditors, now working in business consulting and private equity. The interviews

    explored, among other things, perceived key attributes, abilities and professional identities of

    auditors, the basic rationales underpinning current audit practice, the extent to which suchpractice has changed or been under pressure to change over the last few years, the contribution

    that auditing activity makes within particular firms, both in terms of income generation and its

    impact on the firms operational culture, and the main areas where change, as it is now

    perceived, will happen.

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    In the next section we address the first problematic, the conditions in which BRA emerged as a

    response by audit firms to problems they themselves have defined. We detail the discursive

    rationales and institutional emergence of BRA, and link these to the development of audit firms

    and the status of audit within such firms during the 1990s. .

    Business Risk Auditing, Audit Practices and Organizational Legitimation

    As Alvesson has argued (1994; 1999), in certain areas of professional expertise, where

    professional abilities and the quality of work are difficult to observe, and knowledge is a

    slippery concept, the claim to knowledge by professions will be routinely supported by the

    management of rhetoric, image and social processes in order to anchor competence within the

    professions environment. As such, even a core professional expertise that has been embedded

    in the accounting profession for decades, such as audit, is supported by processes that reaffirm

    professional expertise to a public that seeks further assurance, or, perhaps, shows an

    uncomfortable propensity towards different expectations.

    As our opening discussion suggested, the emergence and announcement of BRA is, perhaps, a

    more than usually public event. Companies are, of course, legally required to have audits of

    their accounts conducted, and competition between the professional firms for audit business has

    been intense. Since the late 1980s audit clients have become much more prepared to shop

    around for their audit (Greenwood & Lachman, 1996). The contest for audit clients has also

    contained audit fee levels. Indeed, audit firms appear to have been keen to lowball (Sikka &

    Willmott, 1995) the bid for audit in the hope or expectation that the provision of non-audit

    services will be a sufficiently lucrative and offsetting source of profitability. As such, analysis of

    the market for audit labour and audit services has become an important approach to

    understanding professional change (Robson et al., 1994). The growth of the international client

    base has been one condition for an intense spate of mega-mergers between the large audit

    firms from the Big Eight to the Big Five, and, more recently, with the collapse of Arthur

    Andersen, to the Big Four, a process that seems to have been conducted in conjunction with an

    ever increasing diversification in the services offered by such firms (Dezalay, 1991, p.793).

    While some methodological problems with the measures remain, there is some justification foraffirming the supply of audit services market as highly concentrated (Moizer & Turley, 1989;

    Pong, 1999; Tonge & Wootton, 1991).

    Rarely, perhaps, has the technologyormethodologyof the audit itself been promoted so visibly

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    as a vital component of the audits merchandising instrument (Power, 2000). Other

    developments in audit methodology such as risk sampling in auditing appear not to have

    attracted the same kinds of public proclamation. The presence of texts such as The Financial

    Audit Statementhas signalled a highly visible marketing of the statutory audit function, and is

    indicative of the radical shift in audit that some commentators (e.g. Power, 2000) have implied.

    As Lemon et al. (2000) have observed, while KPMG has been a central figure in the

    establishment of the BRA methodology during the 1990s several of the major international

    accounting firms developed their methodologies on the basis of business risk analysis (p. 1).

    Accordingly, as Lemon et als study of business risk methodologies encompassed three

    countries3, all the Big Five (as was) and two or three of the largest second tier firms in each

    country, the authors were assured in stating that while some differences of approach existed the

    BRA approach in all firms

    There is good reason to view the business risk approaches as a significant innovation

    to the existing model (Lemon et al., 2000, p. 10).

    Much of the BRA innovation consists of the focus upon the modelling of risk in business

    processes as the basis for establishing financial statement risk and, accordingly, the focus of

    audit testing. The following from Bell et al., (1997, p. 50) summarizes the key differences

    between traditional audit and BRA:

    Figure 1

    Comparison of Traditional and New Business Risk Control Paradigms

    Old Paradigm

    Risk assessment occurs periodically

    Accounting, treasury, and internal audit responsiblefor identifying risks and managing controls

    Fragmentation every function behavesindependently

    Control is focused on financial risk avoidance

    Business risk controls policies, if established,generally do not have the full support of uppermanagement or are inadequately communicatedthroughout the company

    Inspect and detect business risk, then react at thesource

    Ineffective people are the primary source of businessrisk

    New Paradigm

    Risk assessment is a continuous process

    Business risk identification and controlmanagement are the responsibility of all membersof the organisation

    Connection Business risk assessment andcontrol are focused and coordinated with senior -level oversight

    Control is focused in the avoidance ofunacceptable business risk, followed closely bymanagement of other unavoidable business risksto reduce them to an acceptable level

    A formal business risk controls policy is approvedby management and board and communicatedthroughout the company

    Anticipate and prevent business risk, and monitorbusiness risk controls continuously

    Ineffective processes are the primary source ofbusiness risk

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    The process of financial statement attestation incorporate greater added value client service

    by allowing the auditor to comment both upon business risks and the accounting implications of

    those risks. Business risk audit is also widely understood to offer audit firms economies of

    professional audit labour. Lemon et al., (2000) suggest that this top down approach to auditing,

    starting with the business processes and down to the financial statements, offers greater audit

    effectiveness, efficiency, client service, better corporate governance and consistency at an

    international level4.

    In the promotion of BRA methodologies, the claims of KPMG appear to have been particularly

    influential. Notwithstanding the populist presentations of evolving auditing, the 1997 publication

    ofAuditing through a Strategic-Systems Lens: the KPMG Business Measurement Process (Bell

    et al., 1997) is widely regarded as an important formal, technical expression of the BRA

    philosophy of auditing (Power, 2000)5.

    The oratory of this text also bears careful scrutiny. Many of the same claims to the value

    creating or value-adding role of BRA are found here as in The Financial Statement Audit. While

    some sections ofAuditing through a Strategic-Systems Lens appear to have been significantly

    driven by a consumer marketing orientation, most of the text aims towards more learned models

    of justification that accord with the normative types of legitimacy that professionals recognise

    and affirm.

    The monograph opens with the following quotation:

    In our time, the confidence, maturity and promise of a science should be measured notby its power to reduce the complex to the simple . . . but instead by its willingness tostudy complexity with advanced methods under descriptions that respect the reality ofwhat is being studied. (David J. Depew and Bruce H. Weber, Evolution, Ethics, and theComplexity Revolution)(Bell et al., 1997, p.1)

    Initially offering a daring indication of the scientific foundation for the new auditing approach, the

    monograph proceeds to establish certain academic justifications for BRA and organizational

    complexity in an involved global economy. To this end, two of the authors, Ira Solomon and

    Howard Thomas were respectively KPMG LLP Distinguished Professor of Accountancy at the

    University of Illinois at Urbana-Champaign and James F. Towey Professor of Strategic

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    Management also at the University of Illinois at Urbana-Champaign. Moreover, while the first

    named author, Timothy O. Bell, is Director of Assurance Services at KPMG LLP, he was also

    previously a member of the accounting faculty at the University of Texas at Austin. The

    monograph also has a preface by William Kinney, one of the most senior figures in American

    auditing research over the past three decades.

    The text runs through the methodological underpinnings of BRA, the relationships between

    strategy, business risk and audit, but gestures towards other, quite diverse, knowledge claims to

    justify the new audit. In no small wayAuditing through a Strategic-Systems Lens aims towards

    the status of a scientific knowledge. The first page continues:

    Accounting plays a central role in the efficient allocation of resources in market-basedeconomies. By adding credibility to accounting measurements and disclosures, auditinghas for centuries made it possible for accounting to play such a key role. Today's globaleconomy and the business organizations operating within it, however, have become so

    complex and interdependent that new approaches to auditing must be developed. Withthese new approaches, the auditor would embrace and master, rather than simplify, thecomplexity inherent in the economic web of interrelationships of which the clientorganization is a part. (Bell et al., 1997, p.1)

    As well as economic reasoning, cybernetics systems methodologies are drawn upon to portray

    the organization as a complex, living system (Bell et al., 1997: 15). Decision sciences modelled

    upon cybernetics are explained in order to outline the organization as a quasi-organic body. And

    New Age physicist/philosophers, such as Fritjof Capra, are cited in support of the holistic,

    systems approach exemplified by BRA (1997: 14).Auditing through a Strategic-Systems Lens

    is a very eclectic mix. The most important point, however, is that Bell et alfurther extend the

    process of reconstituting the knowledge base of audit from compliance and substantive testing

    towards the auditor as business risk assessor. Although the monograph is short on detail as to

    the specific audit procedures and practices introduced or modified by business risk audit

    methodology, its role is to delineate how external audit is remodelled and re-crafted to address

    matters of internal control, internal audit and assurance.

    As others have noted (Power, 2000) one of the anticipated consequences for BRA practice is

    that the requirement for substantive testing of transactions is diminished. Yet while in other

    respectsAuditing through a Strategic-Systems Lens lacks detail as to the nature of the new audit

    practices that constitute this methodology, its significance lies in an elaboration of the bodies of

    knowledge that are claimed to underpin BRA. In an industry in which client confidentiality is used

    to justify the limited access granted to researchers and secrecy of methodology is justified as a

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    competitive weapon, the Bell et al., (1997) document stands out as another example of an open

    public expression of the new auditing, albeit to a different, if overlapping, constituency -

    knowledgeable professionals, regulators and academics (1997). Both KPMG documents, Bell et

    aland The Financial Statement Audit, denote the value adding ideals of BRA as the main source

    of legitimation and, in so doing, announce a revolution in audit methodologies. In legitimating

    business risk audit in these terms, at the same time the profession legitimates itself by attaching

    its expertise to dominant cultural values such as efficiency, rationality and science (Abbott, 1988;

    Dirsmith et al., 2002).

    If the language of justification has the creation of added value for the client as its central theme,

    then plainly this is all of a piece with the competitive and concentrated market environment for

    audit clients previously outlined. Moreover, while the overall structure of the profession has been

    marked by mergers and audit concentration, the internal organization and culture of the large

    audit firms are equally relevant to the development of the new audit methodology. By shifting therationale of audit to encompass business advice, BRA offered auditing the potential of enhanced

    standing as a practice within the large firms. The spectacle of the split between Andersen

    Consulting and Arthur Andersen in 1999 was indicative of the tensions and rivalries between the

    self-styled value adding activities of Professional Service Firms non-audit services and the

    statutory practice of audit attestation. Although plainly the provision of statutory audit to a

    corporation is, at the same time, a conduit to the provision of many value creating non-audit

    services (tax, management consulting) the studies that exist of audit firm culture (Anderson-

    Gough et al., 1998a, 1998b, 2000; Dirsmith et al., 1997) have affirmed that audit is now

    accorded low status in the hierarchy of the Big 5 professional service firm activities. Whereas ten

    years ago there were less than a handful of qualitative and ethnographic studies of accountants

    (Dirsmith & Covaleski, 1985; Harper, 1988, 1989), the present decade has seen something of a

    proliferation of such work (for a review, see Anderson-Gough et al., 1998a, 1998b, 2000; Coffey,

    1993, 1994; Dirsmith & Covaleski, 1985; Grey, 1994, 1998; Hanlon, 1994). We now know a

    great deal more about how accountants live their daily lives and enact professionalism, at least

    in the large public accounting firms.6 Such studies of audit trainee and professional socialization

    in the UK and the US large audit firms share many of the same judgments as to the constitution

    of the accounting professional and the main features of professional identity amongst auditorsand trainees. Notions of being professional emerging from such work show the significance of

    appearance and behaviour7. The personnel management systems of the large firms have

    reinforced through appraisal forms that the notion of professional, refers trainees personal

    aspects and conduct, especially in front of the client8. This does not mean that auditors lack

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    concern with formal accreditation as professionals - indeed, the contrary. The way in which

    accreditation is conceptualised, however, appears some way removed from the traditional

    picture of the profession as a repository of technical knowledge or as exemplifying a public

    service ethic. Trainee accountants in the process of learning these conventions seem to

    demonstrate that professional behaviour is conducted and rationalised in the name of client

    demands. The client discourse is a significant factor in the organizational control of these firms

    (Anderson-Gough et al., 2000).

    For audit trainees for example, the act ofqualifyingas a Chartered Accountant, or, more exactly,

    havingthe qualification, now seems to provide the overriding discursive rationale for taking

    employment with a Big audit firm. Whilst other trainee professionals may choose their

    profession and begin their training with a strong sense of why the work they will be doing is

    important to them and the public (and perhaps see this service ethic corroded later), trainee

    accountants seem to place little value on the profession per se. As the client service ethic isclosely connected to commercial awareness (and seizing the opportunities to expand the firms

    non-audit services), it is unsurprising that while many audit trainees consider the possibility of a

    career within the large audit firms, the audit task is commonly perceived as one of the lower

    prestige points of the audit firm hierarchy. As Anderson-Gough et al. (2000) concluded:

    Notwithstanding the claims of practicality and general business training that traineesattach to their work in audit firms, one curious element of this is the low esteem in whichaudit is held once qualified. Audit is no longer held to be a lucrative, challenging orenticing career within the firms by the majority of those who either leave or remain withthe firms in the hope of future partnership. (p. )

    Part of this erosion of status appears to be allied with audits declining profitability; despite the

    unmistakable strategies of the large firms to treat audit as the gateway to the pursuit of the more

    diverse and financially rewarding non-audit services; audit fee pressure aside audit partners

    couldjustify the value of the audit function to the firm as a subsidised or loss leading activity.

    The increasing emphasis in the firms for managing partners through measures of fee income,

    realisation rates and profitability, however, suggests that in practice that audit partners are just

    as subject to the same financial targets as their senior managers and partners in other

    commercial divisions of the firms (Covaleski et al., 1998).

    The propensity for corporations and other third parties third parties to litigate against the global

    audit firms has also impacted upon the risk and return associated with audit (Tonge & Wootton,

    1991). In turn this has incentivized the large audit firms, as Covaleski et al., (2002) have

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    suggested, citing the AICPA, to migrate up the economic value chain and lay claim to wider

    areas of management expertise and consultation. In short, the professional identity of

    accountants trained within audit firms has become closely connected with the discourse of client

    service and adding value to the client to the extent that traditional audit functions, and the audit

    divisions providing such services, have lost status in their own organizations. A number of our

    interviewees noted that audit partners were not generally seen as major players within the firm

    partnership structure (although there were some exceptions) and that audit partners were

    continually under pressure to demonstrate improved recovery rates.

    Seen in these terms, BRA offered an attractive re-conceptualization of the audit craft. Re-

    inventing audit as a commercial practice has offered an opportunity to recapture the prestige that

    the declining profitability of audit had eroded. The notion of adding value to the client embedded

    in the new audit methodology resonated closely with the identification of corporate management

    as the essential audit client (for more discussion, see Anderson-Gough et al.,1998; Humphreyand Moizer, 1990). Accordingly, BRA presented both an external legitimation to the client and

    an internal justification of audit to the seemingly higher status functions and divisions of the

    modern large professional service firm. As such, perhaps the business risk audit event marks

    another stage on the transition of the accountant and auditor from professional expert to

    businessperson.

    However, if these rationales offer a justification to the clients and the firms themselves, the

    embedding of BRA has required the enactment of other processes of legitimation and

    transformation. The next section explores how the professional associations of accountancy

    have been enrolled to facilitate the BRA methodology.

    Institutionalizing Business Risk Audit

    Whilst the emergence of BRA has tried to push the market appeal of audit from a statutory

    requirement towards a form of quasi-management consulting, and as such has signalled a

    change in the rhetoric of audit, the embedding of BRA in the organizational field of the profession

    has been an ongoing political project for the audit firms and their professional association

    (Covaleski et al., 2002). The large firms advertising brochures and academic monographs havebeen supplemented by the overlapping involvement of the professional institutions.

    Covaleski et al. (2002) indicated how the re-alignment of the services provided by professional

    service firms can be characterized as a dramaturgy of exchange relations between the large

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    firms and the professional associations that speak for the profession. The aspirations of the

    large firms in the USA to re-define themselves as global knowledge experts encompassed not

    only themselves, but also the AICPA, the SEC and the Institute of Internal Auditors (IIA) in

    debates and conflicts over the role of auditing professionals and the economic relationships

    between audit firms and their clients.

    In the UK, the acceptance of BRA has seen an adjustment of practices associated with the

    professional institutes. Although BRA is almost exclusively assocuiated wi the largest vof the

    audit firms, the professional associations in the UK have facilitated a wider acceptance of the

    assurance methodology. One key element of this exchange has been a struggle between the

    large and small firms to re-structure the education of prospective accountants and auditors. As

    Lemon et al. (2000) suggested, the introduction of BRA embodies assumptions about the

    expertise and competences of auditors:

    A business risk approach emphasises judgement, and broad skills to be able to assessthe position of a business in its environment, matters of strategy, operations andfinance. This has implications for the nature of the formal qualifications recognised asappropriate for auditors, for the structure of educational courses accredited in theprocess of qualification and the recruitment and training of audit staff by the publicaccounting firms. there is a heavy emphasis on strategic management embodied inthe business risk approach and, as a consequence, auditors conducting audits underthat approach will have to be strongly conversant with the strategic managementliterature (p. 22).

    Revising the intellectual content of professional training has helped to assert the case that the

    accountant or auditor has the established competence or expertise to conduct a re-invented

    audit function. Demonstrating command over, and the appropriate credentials for (Reed, 1996),

    an abstract body of knowledge is a fundamental element of professional jurisdictional control

    (Abbott, 1988). Without a credible background of expertise and training the claims of BRA could

    be held in question by occupations whose competing or overlapping concerns with business risk

    viewed BRA methodologies with suspicion - such as, for example, the professional associations

    of internal auditors. In fact, some years prior to the publication of the Lemon et alstudy, the

    English Institute (ICAEW) had initiated a review of the professional training process. For

    example, in 1996 the ICAEW set up an internal inquiry into the future of the profession and the

    skill set of the accountant of the future. The resulting consultation document,Added Value

    Professionals: Chartered Accountants in 2005, constructed a future in which the possible

    oversupply of chartered accountants and loss of audit work would be compensated by a

    transformation of the audit sector towards assurance reporting to third parties on matters such

    as pensions, internal control, public sector services as well as the traditional audit client (ICAEW,

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    1996: 20-1). By setting out the agenda for the UK profession in these terms the 1996 report set

    in train a series of reform to professional accreditation that would put together the future in these

    terms.

    In part the added value business professional ideal reflected the potency of the large firms,

    though in practice this leverage operated through the engagement with issues by their

    appointees to the relevant ICAEW internal committee. The chair of the key ICAEW committee

    responsible for educational matters, the Education and Training Committee (E&T), Peter

    Wyman, a senior tax partner in what later became PricewaterhouseCoopers9, had begun a

    review of the structure and curriculum of the examinations constituting the professional

    qualification process. The ICAEWs E&T Committee issued in a Green Paper in 1998 entitled

    Creating the Added Value Business Advisor, which in many ways served to reinforce the validity

    of business risk auditing. The Green Paper recommended the adoption of specialist pathways

    within the training process. Whilst certain technical skills remained core to the training process,the Green Paper proposed elective routes within the examinations process to broaden the

    potential education of prospective entrepreneurial accountants. Wyman travelled across

    England and Wales to make presentations to Local District Societies explaining the proposals

    and bring on board the medium and small accounting firms. Representatives from the smaller

    accounting firms regularly voiced concerns in public meetings and in the financial press at the

    diluting of core accounting competencies, in favour of a more general business or, perhaps,

    even MBA style education. Though such programmes to educational curricula are rarely without

    controversy, the changes suggested by Creating the Added Value Business Advisor were

    consistent with the skills changes that subsequent BRA methodologies have claimed as being

    necessary if traditional accountants are going to be capable of becoming business risk

    assessors.

    Professional auditing standards make up another arena in which the new audit methodology has

    to be assimilated. To this end, on both national and international auditing regulatory stages,

    business risk audit has stimulated the development of new auditing standards orientated towards

    the new methodologies and which in turn add validity to BRA as a professional audit practice.

    For example, the Audit Risk Project of the International Auditing and Assurance StandardsBoard (of the International Federation of Accountants) was set up explicitly to integrate the

    regulation of audit risk assessments with the design of audit procedures. In October 2002 the

    IAASB issued four replacements for previous ISAs that dealt with Internal Control and Computer

    Information Systems (IAASB, 2002a, 2002b, 2002c, 2002d). Whereas previously risk

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    assessment standards were considered a separate niche issue for regulations and auditing

    standards, new standards regulating the quality of risk and risk assessments are central

    components of the assessment of financial statement risk- -in other words, they now assume the

    BRA methodology and in so doing reinforce its centrality to the audit process. BRA is

    established as the legitimate object of regulatory activity and becomes further embedded in audit

    practices.

    Of course, the programmatic ideals of BRA are by no means concluded and thus far the

    potential for conflict between professional members or the accounting profession and other

    occupational groupings appears not to have been that visible. Yet as Covaleski et al. (2002)

    have shown in the USA, as part of a wider programme of outsourcing of internal control issues in

    corporations, actions by the AICPA supported by the large firms have brought them into dispute

    with the Institute of Internal Auditors. In the UK, where the professional groupings associated

    with internal auditing and control are much less visible and more fragmented, possibly theopportunities for the Big 4 firms to extend their jurisdiction appear less obstructed. Nevertheless,

    it would appear that competition for the corporate internal control market has intensified with the

    advent of BRA (Power, 2000; Dezalay, 1991).

    In summary, business risk audit (BRA) has offered to the audit industry and the profession a new

    form of rationality and legitimacy for the audit task. Audit or rather assurance appears to occlude

    the distinction between audit and business (or value adding) services in a seeming harmony of

    interest between auditor and corporate management. As such BRA has not so much

    marginalised audit independence (Jeppesen, 1998; Power, 2000) as recast the audit as a

    process of mutual interestbetween the business director and the auditor (Power, 2000). Already

    the fixing of BRA in the educational training of auditors is in process and regulators appear to

    have been persuaded to adopt BRA as the defining methodology of audit for standard setting.

    The next section of the paper examines the tensions that have emerged from the re-invention of

    audit, starting with the relationships of accounting professionals to their institute and to each

    other.

    Tensions in the Professional Audit CoalitionTwo former PricewaterhouseCoopers partners have formed a 'new concept'audit firm, which will focus on helping companies meet the requirements of theHiggs' report and promises to be completely independent of the company itaudits.

    According to its founders, Jonathan Hayward and Richard Sheath, Independent

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    Audit Limitedhas been set up in response to the Enron and WorldCom scandalsand will provide financial and corporate governance analysis - reporting solely to[company] boards and audit committees.

    As its name suggests, the firm says it will ensure that 'total independence frommanagement is maintained'. (Larry Schlesinger, Accountancy Age, 17thFebruary 2003 - emphases added).

    To date the effect of recent US large audit failures on the professional coalition is uncertain.

    Thus far there seems to be a mismatch between the definite, almost clear-cut, nature of

    proposals for reform (such as the banning of consulting services, compulsory auditor rotation,

    more detailed audit reporting etc.) and a recognition that, with BRA, audit as conducted by the

    large audit firms is not what it was. However, from our interviews it is apparent that a source of

    tension has developed further between the concept of audit as understood by the small and

    medium firm practitioners and that of large firm auditors.

    As Power (2000) has indicated, in part the rationales of BRA can be equated to the old adage

    that an auditor needs to understand the clients business. Yet in the same way that BRA has

    contributed to a radical redefinition or reinvention of audit, so we observe more clearly

    contrasting understandings of audit amongst accounting and auditing professionals. For some

    of the firms the scope and role of audit work goes beyond established and largely agreed notions

    and understandings of audit - We are no longer just auditors, but we are respected business

    advisers. Some smaller audit firms still have financial statements at the forefront: the theory of

    it hasn't changed, the practice of it hasn't actually significantly changed, an audit file that you

    pick up from a department today is very much the same as far as evidence and everything else

    is concerned as one that you picked up twenty years ago.

    Audit now emerges as a much more varied, ill-defined and intangible service than implied or

    assumed in standard proposals for audit reform. In interviews it was apparent that many

    supposedly key auditing concepts (such as independence) were often not readily or explicitly

    referenced. Indeed the current lack of taken-for-grantedness of audit independence was the

    motivation (as illustrated at the beginning of this section) for some auditors to proclaim as a new

    audit concept the firm that is concerned primarily with independence. While the discourse for

    change seems to articulate more client-driven rationales, developing audit methods (such as

    risk-based auditing) can be interpreted in different ways. What drives auditors is a complex mix

    of influences, including their own perceptions of their position within the firm, prior training and

    experience, the way in which their performance is assessed and official auditing standards and

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    practices within the firm and the profession more generally.

    For example, many small firm practitioners remain sceptical as to the methodology of BRA. The

    push in recent years for the audit to become an added-value business service was commented

    upon with a sense of irony by many of the small-firm practitioners and, indeed, by some of the

    large firms:

    People go through fads and fancies and most things in auditing do go around incircles.you wait long enough and it [theold methodology] will be back again

    Many small practitioners were concerned that the processes of reinventing the audit had

    effectively cut audit work back to its bare bones and that, post-Enron, people had started to

    realise this and were gradually seeking to increase levels of audit testing. Moreover, most small

    practitioners asserted that the BRA philosophy (creating firm value) reflects a working model that

    they had effectively been operating with on their owner-managed business clients audit - the oldadage of knowing the business and where their audit was usually coupled also to accounts

    preparation and tax advice. In short, small firm practitioners believe that they know their clients

    business but are sceptical as to the capacity and ability of the audit divisions of the Big 4 firms to

    offer the same degree of understanding through BRA. One sole practitioner reported that while

    the proposal to increase the audit exemption for small firms had initially been a cause for

    concern, the fact that he had always been operating within a value-enhancing model meant that

    revenue streams were not at stake. In commenting on such a state of affairs, he reflected much

    of the business model currently underpinning the BRA philosophy in larger firms:

    It did concern me at some stage when it (audit exemption reform) was first mooted. Isuppose I was wondering where my next pound was going to come from, but then themarket has changed. Im doing more and more accounting, business management,finance director type stuff than I ever did, and thats what clients want

    Many interviewees, particularly from non-Big 4 firms, saw a need for audit reforms to distinguish

    between audits of multinational public limited company audits and smaller, largely,

    owner-managed entities:

    What I would like to see is that they [the standard setters and the ICAEW] should makea distinction between - clients that have public exposure, listed entities particularly andthe rest. I think there's a tendency to one rule for all and I don't think that suits becauseI think it makes it impractical at the smaller end of the scale with owner managedbusinesses to do certain other things ....

    The public limited company audit environment was viewed by small practitioners as

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    interviewees employing the more traditional notions inorder to describe their professional identity

    typified by the way respondents felt that they were, first and foremost, auditors. That said,

    while stressing the benefits of the traditional compliance role of the auditor, they also saw that

    such a function was always likely to deliver broader benefits to the client:

    I dont think our approach has changed very much at all. Its always involved someelement of understanding of the clients business, understanding the risks, the internaland the environmental risks. The added value is really in the people that theyre dealingwith. I suppose its worth saying that if Id have thought my role was just about auditing, just going in and checking terms, then I would still not be here after 18 years. Theenjoyment I get is actually dealing with the guys that run their businesses, and helpingthem grow. You build up a relationship with them, but it obviously has to remainindependent and objective

    We would find it harder to advise them successfully if we didnt do the audit, becauseyou learn a lot about the business from doing the audit. Equally, you learn a lot aboutthe business through providing other services - which helps you in your audit. Taxcompliance is an area where if you dont do the audit, it becomes quite inefficient.Theres so much information on the audit file which you, and only you know, and youre

    not going to give that to others

    Both small and mid-tier auditors were of the belief that the provision of integrated or

    complementary services did not give rise to potential conflicts of interest largely because they

    were mainly dealing with owner-managed clients. However, they saw the issue of separating

    auditing and consulting work as being very relevant to the Big 4 firms:

    Advising on value is the biggest problem with relationships (corporate finance work)and independence (audit work). Because youve already said that a business is worthXm on the audit, then with the corporate finance work, can you come along and say itsworth peanuts?

    There is a paradox related to the size of the firm. The big four offer advisory servicesin a compliance environment, and in this setting, it needs to be split

    Yes, definitely on PLC audits... auditors should not be a jack of all trades and mastersof none

    I think we have a lot of sympathy with the view that smaller businesses dont need anaudit. Its obviously part of the debate as to what extent theyre exposed to greater risk.I think theres a difference between the listed companies and others. Companieswhere people can invest and youve got a big divergence between ownership andmanagement. There is, I think, an argument, a good argument that listed companiesshould be dealt with separately. Where I am not convinced is that compulsory rotationwill achieve anything. Youve only got four firms really and theyre just going to be

    moving them around from one firm to another

    These separate identities were evidenced, and thereby maintained, through the firms

    employment policies. A small size audit firm partner reflects on his experience with people he

    had employed from the larger firms:

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    I've employed people from the big five, or the big four as they now are, and they're justtotally not with-it as far as this level of work is concerned, they can't tune into therequirements and the needs of the man in the street [] the guy who I employed fromone of the big four was - yes, he was a chartered accountant, he just ticked boxes, he'ddone the audit, the accounts came off the computer, he was quite computer fluent, lap-tops and all that, he didn't sit back to think 'well, what do they mean' - I said 'well, why,

    Philip, have you not done this, what about that - have you not looked at this - what aboutthat, your papers don't say this, your papers don't say that - why, why, why - what if - ',you know, he just hadn't been trained properly in my view

    The smaller-firms saw the skill base of the auditor in narrower, more traditional terms. Given

    their client base, their audit staff had to be well skilled in basic accounting techniques and

    familiar with taxation regulations etc. The one-stop approach adopted by audit clients meant

    that staff had to be good all-rounders, well versed in the fundamentals of accounting.

    Newly-qualified staff from the Big 4 firms were no longer people that the smaller (or even the

    mid-tier) firms would actively seek to recruit as their accounting and audit background was

    perceived to be too narrow. However, middle managers from Big 4 firms were deemed to be

    very attractive employment candidates, reflecting a greater degree of regard from the small

    practitioners for the post-qualification training and experience provided by the medium firms.

    In the large firms, a central attraction of BRA methodologies was that they would help to make

    the audit process more relevant and creative and, therefore, more likely to attract high-flying,

    top-rate graduates into the firms. There were also comments that a broader, business aware

    form of training and practice offered the audit sections within the large firms ways of generating

    respect from client management, as well the potential for generating additional fee income,

    which previously would have been assigned to the business consulting division. The skills base

    being sought, however, was different from the more traditional, accountancy-based skills

    favoured in the smaller firms here it was understanding business and management models

    and key conceptual approaches in organizational strategy and psychology. Again, though, such

    developments appeared capable of generating fragmentation and division. A limited number of

    interviews with partners who had moved out of audit into business consulting and private equity

    firms revealed a real scepticism towards the promotion of BRA methodologies and their

    conceptual underpinnings and assumptions. Audit partners might talk of being relationship

    people but for these former auditors, audit partners were most definitely not relationship

    people. Such former auditors saw business consulting in a more favourable light and clearly

    positioned the audit section as being staffed by people who could not cut it in business

    consulting. Auditors in the smaller firms were also sceptical of the effectiveness of such BRA

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    methodologies. Aside from arguing, as noted earlier that they had been operating a business-

    oriented approach to auditing for a while (and in a manner that they felt was more cohesive and

    appropriate), they felt that many of the professions current problems had been brought on by the

    larger firms overly reducing audit testing levels. Some interviewees in mid-tier firms saw the

    scandals on the scale witnessed in the US as quite desirable in terms of a widening of the client

    base to service larger clients and benefiting from fee increases.

    Divergent Constructions of Auditing and Professional Fragmentation

    From the above analysis, auditing emerges as much more varied, ill-defined and intangible

    service than that which tends to be implied or assumed in standard proposals for audit reform.

    Supposed key auditing concepts (such as independence) are not readily referenced by

    respondents, while business-oriented audit methods and philosophies are capable of being

    interpreted in very different ways. What drives auditors appears to be a complex conjunction of

    influences, including perceptions of their firm, its traditions and systems, their status and rank

    within the firm, prior training and experience, the way in which their performance is assessed,

    and the profession more generally. That auditors struggle to identify any clear routes for reform

    is a consequence of the environment in which they operate as interviewees regularly pointed

    out, simplistic reforms are likely to prove problematic when confronted with the operational

    complexity of audit practice. The danger for auditors is that they are currently rather marooned

    in this environment and quite limited as to what they can contribute to current debates. On one

    level, there is a danger of publicly acknowledging that things are a whole lot less certain than

    official professional proclamations would admit. On another level, there are powerful myths and

    traditions that are hard (if not dangerous) to discount. Thus, should auditors come clean in

    terms of what they do and dont do on audits instead of hiding behind the mystique of auditing?

    Should they be more communicative in audit reports or will all this detract from the so-called

    deterrent effect of auditing? Can the audit process continue to develop in ways that may

    appear to be more supply-driven than demand-led; more about what audit firms wish to provide

    rather than what audit stakeholders desire? Should auditors start to challenge more explicitly

    other elements of the profession or maintain a rather more distanced (and distinguished stance)

    of not criticising fellow professionals? Can the audit of multinational corporations continue to be

    treated as the legitimate domain of the Big 4 firms, given the questions that have been raisedover the strength and merits of their current audit approaches and underlying audit

    philosophies? Should smaller audit firms be more vocal in expressing their preferences and

    desired strategies instead of accepting that they are unlikely to appear highly on the agendas of

    the Big 4 partners who so often represent the professional accountancy bodies of which they are

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    all members?

    Concluding Comments

    The emergence and dissemination of new audit techniques and methodologies have not

    received the attention in academic research that is merited by their significance. In the

    processes of establishing new claims to knowledge, there is the opportunity to examine the

    professional and social processes through which such claims emerge and the extent to which

    attempts are connected to the extension of professional jurisdiction. In so doing, the dynamics

    that underlie the institutions of the profession may be revealed and subject to tension. The

    papers title signals three interrelated dimensions of this technical-professional interface: status,

    identity and fragmentation.

    The new audit techniques and their associated discourses and rationales are intertwined with

    the status accountants and auditors perceive of themselves and their craft, and their identity as

    auditors (or business advisers). In the moments of realizing new audit methodologies, they

    allow us to explore the tensions that exist or fractions that may emerge between institutional

    agents and interests in the profession. The aim of this paper has been to explore the extent to

    which the new audit methodology of BRA has been promoted by firms, and institutionalized in

    practice, what rationales are used by firms adopting BRA to legitimize the change, what are the

    different views expressed by the different concerned groups towards BRA, especially those of

    smaller firms, and the impact of such change at the organizational and professional level,

    especially post Enron.

    Although BRA methodologies have dominated audit discourses over recent years, evidence

    presented in this paper suggests that within certain sectors of the profession, there is still

    scepticism expressed about their added value. Concerned groups not only doubt the inherent

    technical validity of such methods but also the conceptual change at the level of the idea, scope

    and role that audit plays in general. In all of this the lack of empirical analysis of contemporary

    audit practice and its implications for the status and identity of the profession remains striking.

    While the professional discourse in favour of BRA methodologies appears to articulate client-

    driven rationales, developing an understanding of how these methods gain legitimacynecessitates critical investigation of more complex mix of influences that are related to both the

    supply of and demand for audit. Although the large firms have attempted to establish the

    argument that the shift towards more risk based approaches is a response to demand, this

    paper argues that the call for change is, in market metaphor terms, supply driven by the large

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    firms, who brought into play these new methodologies through their auditing practice, to

    renegotiate terms of their professional status and widen their jurisdictional claims over other

    areas of expertise. Many of the imperatives for BRA are in our view reflective and constitutive of

    the organizational tensions in play within large firms. The BRA event is not simply another

    episode in the transformation of the identity of the Big Six/Five/Four from auditor firm to

    professional service firm (Greenwood et al., 2002). This shifting notion of the accountant as

    business advisor has undermined the status of audit divisions to the extent that the business

    assurance re-invention of audit in part offered a welcome source of internal legitimacy to the

    audit services in the Big Four firms.

    The paper revealed other sources of professional fragmentation between the small and large

    firm sectors. Differences between small and big firms perceptions and commitments towards the

    new methods have highlighted diverse and competing notions of professional identity amongst

    professionals. For example, for some mid-tier firms, audit was and still is the main serviceprovided. Hence, their professional identity hinges around and identifies with certain standard

    notions and attributes of auditing and accounting-based techniques. Larger firms on the other

    hand saw themselves as business advisors and tended to reject the label auditor as a descriptor

    for their work. Invoked by the adoption of BRA as a new methodology, these increasingly more

    irreconcilable differences in professional identities amongst practitioners have implications for

    the profession in general and also the nature of reforms proposed by firms to salvage the

    reputation of auditors after scandals such as Enron.

    In the post-Enron environment, the history of BRA is by no means stabilized. As new retro audit

    firms are established claiming to be truly independent, former external auditors demand that

    auditors re-connect with shareholders (see Acher, 2002) and evident differences appear in the

    views of members of the accountancy profession as to how auditing should develop (see

    Humphrey et al., 2002), a lively period of further change in the market services probably lies

    ahead. The increasing emphasis upon mechanisms of corporate governance and the role of

    non-executive directors might paradoxically offer a challenge to audit, signaling a lack of

    confidence in the ability of auditors to deliver whatever it is the audit is intended to deliver - a

    question that, as we have seen with the audit expectations gap debate, has never been settled.As Big Firms have attempted to move ahead from audit to business advice, on the success or

    failure of the BRA methodology might rest the entire market for audit in the future. Indeed, it

    could be argued that the auditing profession is very much at a crossroads - but it is not the

    typical one portrayed in the media, centred on the need for auditors to become more active in

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    detecting fraud and preventing corporate collapses. While the latter issues are significant, they

    represent claims and expectations that are too divorced from the day-to-day practice and

    routines of auditors and audit firms. Rather than accepting wish-list items or trying to fight them

    off as inappropriate, we believe it is likely to be far more socially productive to develop

    understanding of the practical achievements of todays audit methods (Eilifsen et al., 2001), of

    the ways in which auditors behave and are treated within the firms and the extent to which

    performance measurement systems and cultural perceptions as to the relative status of auditing

    impact on auditor performance.

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    Endnotes

    1. While traditional audit is arguably heavily dependent on a compliance mode of regulation, it alsodepends upon deterrence - a mode of regulation not addressed by the BRA literature.2. The argument here is that judgments of materiality in transactions testing is in its own way anacknowledgement of risk.3. US, UK and Canada.4. Mark Davies, a Canadian Assurance partner in KPMG Toronto, describes the top down risk based auditas analogous to determining the health of the tree by identifying and focusing attention on branches mostlikely to be diseased.5. The text has recently been supplemented by a book of cases on strategic-systems auditing (see Bell &Solomon, 2002).

    6. There has been very little empirical study of smaller firms or of accountants in industrial settings.7. This notion of professional conduct was in part communicated to the trainees through their formalappraisal procedures (see Covaleski et al., 1998) and the competencies they defined: leadership,commercial awareness, client service, etc.8. Covaleski et al. (1998) have argued that the focus on the personal aspects of dress, and make up andother aspect of personal appearance extends also to partners. In their study of US auditing firms theynoted the sanctions against such items as rubber watches, short socks, white pantyhose and beingseen, in the garden of your own home, shirtless.

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    9. Wyman is the current President of the ICAEW.